Understanding TPDES Permits and Texas Wastewater Regulations

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Learn about the Texas Pollutant Discharge Elimination System (TPDES) permits and regulations governing produced wastewater in Texas. Explore the authority of regulatory bodies like the Texas Commission on Environmental Quality (TCEQ) and Environmental Protection Agency (EPA). Discover management options for produced wastewater and the importance of TPDES permits in controlling pollutants in surface waters. Dive into the different types of TPDES permits and their role in protecting water bodies through assessment, control, and monitoring of wastewater streams.

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Produced Wastewater Permitting November 2, 2023

Produced Wastewater Regulatory Authority Texas Legislation Regulatory Authority Railroad Commission of Texas (RRC) Environmental Protection Agency (EPA) Texas Commission on Environmental Quality (TCEQ) 2

TPDES MOA Addendum January 15, 2021 Transfer of Oil and Gas Permitting Authority New and Pending Individual Applications Effective (Active) Individual Permits Effective (Active) General Permits Transfer of Compliance Monitoring and Enforcement Authority New and Pending Individual Applications Effective (Active) Individual Permits Effective (Active) General Permits Permits with Pending Enforcement Actions Transfer of Information and Records Notification to Permittees

Produced Wastewater The fluid brought up from the hydrocarbon-bearing strata during the extraction of oil and gas, and includes, where present, formation water, injection water, and any chemicals added downhole or during the oil/water separation process. [40 CFR 435.33 (v)] Management Options Reuse within the oil field Disposal by underground injection Treatment and disposal by discharge to surface waters 4

Texas Pollutant Discharge Elimination System (TPDES) The Texas Commission on Environmental Quality (TCEQ) is federally delegated by the U.S. Environmental Protection Agency to implement the TPDES program to control discharges of pollutants to surface waters of the Unites States. TPDES permits are developed under Chapter 26 of the Texas Water Code, which authorizes TCEQ to set requirements in a permit before an entity discharges wastewater into the surface waters of the State. TCEQ prepares TPDES permits that comply with state and federal water quality rules and regulations: individual authorizations general permits 5

TPDES permits Protect the quality of water bodies by: Assessing the wastestreams and receiving waters Controlling pollutants discharged from point sources Effluent limitations Monitoring and Reporting (M/R) requirements 6

TCEQ Types of Permits One Individual Permit and Five General Permit Options Wastewater Permit Types 1. Texas Pollutant Discharge Elimination System (TPDES) Individual Permits 2. TPDES Oil and Gas General Permit TXG310000 Pending 3. Outer Continental Shelf General Permit WQG280000 Pending 4. Hydrostatic Testing General Permit TXG670000 Stormwater Permit Types 5. Construction General Permit TXR150000 6. Multi-Sector General Permit TXR050000 Amendment Pending 7

Overview Three wastewater general permits TXG310000 - East WQG280000 - East TXG670000 - Statewide Two stormwater general permits Statewide Individual wastewater permit Statewide 8

TXG310000 New general permit to authorize new and existing onshore stripper well facilities coastal facilities territorial seas facilities For activities EAST of the 98th Meridian 9

Onshore Stripper Well Facilities TXG310000 Authorize discharge to surface waters produced wastewater well treatment (not hydraulic fracturing fluids) workover fluids Prohibition of discharge to surface waters drilling fluids drill cuttings produced sand dewatering effluent formation test fluids well completion fluids hydrate control fluids domestic waste sanitary waste contaminated miscellaneous discharges and uncontaminated miscellaneous discharges contaminated stormwater 10

Coastal Facilities TXG310000 Authorize discharge to surface waters deck drainage domestic waste sanitary waste (M10 and M9IM) uncontaminated miscellaneous discharges contaminated miscellaneous discharges Prohibition of discharge to surface waters drilling fluids drill cuttings produced wastewater produced sand dewatering effluent formation test fluids well treatment, completion, and workover fluids hydrate control fluids contaminated stormwater from inland facilities (located on land and not located in a bay, estuary, or wide tidal river where such discharges are considered deck drainage) 11

Territorial Seas Facilities TXG310000 Authorize discharge to surface waters produced wastewater hydrate control fluids well treatment, completion, and workover fluids deck drainage domestic waste sanitary waste (M10 and M9IM) uncontaminated miscellaneous discharges contaminated miscellaneous discharges Prohibition of discharge to surface waters all drilling fluids all associated drill cuttings produced sand dewatering effluent formation test fluids 12

How is TXG310000 Different TXG310000 will replace EPA General Permits TXG260000 and TXG330000 TXG310000 will replace individual RRC permits Application processes are simplified Each discharging facility submits an individual application (NOI) Cooling Water intake structure (CWIS) requirements apply Discharge of domestic waste is subject to effluent limitations Revised whole effluent toxicity (WET) limitations and monitoring 13

Effluent & Monitoring Requirements TXG310000 Effluent limitations for discharges to Territorial Seas (Segment 2501) Additional WQBELS for produced water discharge to territorial seas Total Copper, Total Manganese, and Total Zinc Monitoring and Reporting (M/R) Requirements New Total Mercury M/R requirement for produced water Territorial Seas Facility produced water effluent flow limitation 0.126 million gallons per day (3000 barrels/day) 14

TXG310000 Status TXG310000 will replace EPA General Permits TXG260000 and TXG330000 TXG310000 will replace individual RRC permits Continue following EPA s permits until TXG310000 is issued September 14, 2022 EPA submitted recommendations with no interim objection May 12, 2023 June 12, 2023 Public comment period November 29, 2023 TCEQ Commission Agenda Date to consider TXG310000 15

Outer Continental Shelf Between 3 and 10.2 miles of the Texas coastline Beyond 10.2 miles TCEQ has no regulatory authority, and permitting is only administered by EPA. WQG280000 16

Outer Continental Shelf Facilities WQG280000 Authorize discharge to surface waters in Gulf of Mexico produced wastewater hydrate control fluids well treatment, completion, and workover fluids deck drainage domestic waste sanitary waste (M10 and M9IM) contaminated miscellaneous discharges and uncontaminated miscellaneous discharges water-based drilling fluids and associated drill cuttings drill cuttings associated with non-aqueous drilling fluids Prohibition of discharge to surface waters non-aqueous drilling fluids produced sand dewatering effluent formation test fluids 17

WQ280000 New state general permit to authorize discharges to Gulf of Mexico Outer Continental Shelf Between 3 miles and 10.2 miles (3 leagues) from shore Beyond Segment 2501 WQ280000 does not replace EPA General Permit GMG290000 EPA does not delegate NPDES authorization past 3-mile boundary Apply for state WQ280000 permit and maintain federal permit November 29, 2023 TCEQ Commission Agenda Date to consider WQ280000 18

Hydrostatic Test Discharges A method of determining the hydraulic and structural integrity of a vessel by either introducing water into the vessel or submerging the empty vessel in water. 19

Hydrostatic Test Discharges TXG670000 Available statewide general permit for discharges of hydrostatic test water From crude oil and natural gas operations for Exploration Development Production TXG670000 issued October 2020 Expires April 5, 2025 100 operations active TXG670000 permits (October 2023) Prior to transfer of permitting authority to TCEQ, hydrostatic test discharges required individual permit authorizations from both EPA and RRC. 20

Stormwater General Permits Statewide TPDES general permits for stormwater discharges from construction activities and certain industrial activities. Construction General Permit (TXR150000, CGP) Amended to expand applicability for non-exempt oil and gas construction activities Multi-Sector General Permit (TXR050000, MSGP) Will be amended (2026) to allow coverage of non-exempt oil and gas exploration, production, processing, or treatment operations or transmission facilities Obtain coverage under the federal EPA MSGP 21

Individual wastewater permits When is an individual industrial permit required? Required for facilities that do not meet requirements of a general permit What oil and gas activity may require an individual permit? Oil and gas extraction Natural gas processing plants Stripper wells Updated Industrial TPDES permit application Updated Administrative Report (TCEQ-20893) Updated Technical Report (TCEQ-10055) Worksheet 12.0 oil and gas exploration, development and production 22

Implementation Procedures (IPs) Procedures to Implement the Texas Surface Water Quality Standards (Regulatory Guidance, RG-194) The Texas Surface Water Quality Standards are implemented when issuing permits for wastewater discharges to surface waters of the state. Surface water quality assessment and impairment status are considered, as provided in the Texas Integrated Report. 23

Effluent Limitations Water quality-based effluent limitations are based on the volume of produced water discharge and unique characteristics of the receiving stream (classified segment). Technology-based effluent limitations in 40 CFR Part 435, Subpart E daily maximum oil and grease concentration of 35 mg/L 24

West of the 98th Meridian An individual permit is needed west of the 98th Meridian for many oil and gas activities. Produced wastewater discharge prohibited except if put to beneficial use for agriculture or wildlife purposes. 25

Produced Wastewater West vs East West of 98th Meridian East of 98th Meridian Discharge prohibited except if put to beneficial use for agriculture or wildlife purposes. Discharge allowed in individual permit. Discharge prohibited from coastal facilities. Discharge allowed from stripper wells facilities. Discharge allowed from territorial seas facilities. Discharge allowed from outer continental shelf facilities. Federal regulations limit discharges of produced water from oil and gas extraction operations based on location. Federal regulations also prohibit moving effluent generated in one area to another area for discharge under less stringent requirements. 26

Status of Permits - October 2023 Transferred Authorizations RRC + Combined EPA/RRC + EPA 140 Includes cancelled and expired permits Pending TCEQ Authorizations for Existing Facilities 12 Issued TCEQ Authorizations for Existing Facilities 11 TCEQ Applications or Authorizations for New Facilities 0 (No applications received as of October 31, 2023) 27

EPA review SIC Facility Type Pending Issued EPA will review the first two TPDES draft permits for each of the following SIC Codes that are developed on or after the date of program authorization: 1311, 1321, 1381, 1382, 1389, 4922, and 4925. Subsequent applications may be subject to EPA review. Oil and Gas Exploration 1311 5 0 Natural Gas Liquids 1321 4 10 Drilling Oil and Gas Wells 1381 0 0 Oil and Gas Exploration Services 1382 0 0 Oil and Gas Field Services, Not Elsewhere Classified 1389 0 0 Transmission and Storage of Natural Gas 4922 1 0 Manufacture and Distribution of Gas 4925 1 1 Wholesale of Petroleum Products 5171 1 0 TOTALS 12 11 28